Not everyone is convinced CMS' proposed rule will fulfill the promise to improve the doctor-patient relationship.

Physician groups are still coming to grips with the 1,473-page rule proposed by the federal government updating the Medicare physician fee schedule and outlining changes for year three of the physician payment program which was implemented under the MACRA program.

But when the physicians first reviewed the proposal publicized by the Centers for Medicare & Medicaid Services, they found a lot of faults, which included changes that would hinder the transition of physician practices to value-based payment and a failure to reduce the prices of drugs.

Here are some of the changes the physician groups highlighted:

It could slow the transition to value-based payment.

The AMGA, a trade association that which lobbies for healthcare transformation, said in a statement that the agency “missed the opportunity” to move Medicare provider payments to a value-based system.

The group said it was disappointing that CMS kept a high low-volume threshold for providers to participate in MIPS, one of two payment tracks under the Medicare Access and CHIP Reauthorization Act (MACRA). That will continue to reduce the payment adjustments for providers that are invested in value-based care, the AMGA said.

As authorized by MACRA, providers can earn an adjustment of up to 7% on their Medicare Part B payments in 2021 based on their 2019 performance. However, as indicated in the proposed rule, CMS estimates the overall payment adjustment will be 2%. “We are concerned that CMS has again opted not to recognize the efforts of high-performing AMGA members. As we enter the program’s third year, it is time for CMS to honor congressional intent and use MIPS to create value for Medicare,” said Jerry Penso, M.D., AMGA president and CEO.

It could increase rather than reduce drug prices

The Community Oncology Alliance, a nonprofit association of independent oncology centers, said CMS’ proposal to cut a 6% fee doctors get for drugs dispensed in their offices to 3%, which would apply to new drugs during their introductory period, will not lower drug prices as the government indicated. The proposal was likely to trigger pushback, and it did.

The American Society of Clinical Oncology said the move to cut physician reimbursement for Part B drugs would make the cancer care delivery system more unstable. Monica M. Bertagnolli, M.D., the group’s president, in a statement added that the cuts could hinder patient access to newer, innovative therapies which would potentially stall progress against cancer and almost certainly make it more difficult for oncologists to provide essential services to patients with cancer.

It could cut payments for evaluating complex cases.

The COA is worried about the effect of CMS proposal to restructure the Evaluation and Management (E&M) documentation and coding system to drastically reduce the amount of time doctors must spend on documentation.

Under the proposal, CMS would drastically cut payment for the critical evaluation and management of more complex cancer cases from $172 to $135 (a 22% payment cut) for a new patient and from $148 to $93 (a 37% payment cut) for an existing patient, the group said. While the intent is to streamline reporting, it will severely undervalue the thorough and critical evaluation and management of seniors with cancer, especially life-threatening complex cases, the group said.

In her letter to doctors, CMS administrator Seema Verma said most specialties will experience changes in their overall Medicare payments in the range of 1% to 2% up or down from the new E&M policy, but she said any small negative payment adjustments would be outweighed by the significant reduction in documentation burden.

It could increase costs, keep reporting burden.

The Medical Group Management Association (MGMA) was not happy with CMS decision to continue its policy requiring physicians to document a full 365 days of quality measures rather than 90 consecutive days.

The proposed rule would also require physicians to upgrade to 2015 Edition Certified Electronic Health Record Technology beginning in 2019. The MGMA was also unhappy that the rule would require physicians to make costly upgrades to their electronic health records for 2019 and take further steps toward implementing burdensome appropriate use criteria.